Question juridique clé
How must debt interest be allocated when calculating the maximum amount for the lump-sum tax credit under Art. 11 para. 1 pStAV?
Solution extraite
Debt interest must be allocated proportionally to assets; only the portion corresponding to the income-producing assets is deductible for the maximum amount.
Motifs extraits
The wording distinguishes debt interest from expenses, using a proportional formula for debt interest and a causal formula only for expenses. Systematically and in substance, debt and interest burden the whole assets and are apportioned according to the composition of assets, not by the causal link to specific income.